“Don’t Tell Me the Moon Is Shining; Show Me the Glint of Light on Broken Glass”Anton Chekhov
It is easy to preach what you don’t have to practice yourself. This is precisely what I would be accused of doing, given the fact that I no longer serve as a judge myself and consequently don’t write judgments anymore. The irony, admittedly, is stark; but, as judges like to say- be that as it may, I must write. Judgment writing has been one of the most exciting parts of judgeship for me and I’ve spent considerable time reflecting upon the ways and means to make them better. This column, which is the first in a series of two that I’d write on the subject, captures my thoughts on the art of judgment writing, drawing on my own experiences and the experiences of my colleagues at the bench, in India and abroad. Since the greatest advice on writing is ‘showing’ and not just ‘telling’, I’ll also illustrating each point with some of the best and the worst written judgments, so that we can examine what makes them so.
I’ll also briefly touch upon the broad do’s and don’ts of writing a judgement, international best practices, specific tips and tricks on specific parts of a judgment such as the introduction and the factual background. I will also briefly touch upon the importance of framing specific issues and some rules to make issues more focused. All of this in Part I. In Part II, we will be diving deep into what can be called the very heart of a judgment: the reasoning part. We will also talk about certain words and phrases which are best avoided as they make judgments clumsy and boring to read. Finally, we will wind-up the series with a few thoughts on writing a killer conclusion.
Now, without further ado, let’s start at the start. The question as to how writing a judgment is different from any other form of creative writing may be a good place to begin. We all know – A judge can’t take liberties with facts, but a writer can. A novelist/creative writer creates a world, but the reader can very well choose not to be part of it by simply not picking up the book. As opposed to this, in a judgment, a litigant has no choice but to inhabit the world that the judge has chosen to create for her. There is absolutely no escape. This, to my mind, highlights the sheer importance of a judgment and the responsibility that comes with it; the exercise warrants more attention than it currently does.
Given the fact that the primary audience of a judgment is the consumer of justice – the litigant, a judgment should be readable, clear, precise, unambiguous and capable of being followed. Also, transparency is key. Justice should not only be done but should be seen to be done. Parties to the litigation need to understand the result and the mental/analytical process by which the judge arrived at the final decision.
There can hardly be any dispute that judgment writing is the most crucial aspect of judging. A judge speaks through her judgments. This applies with even great force in case of us – Trial Judges given the fact that for almost the entirety of the population, the Trial Court is the court of first and the last resort, and often a citizen’s only brush with the system, outside, of course, of movies and popular culture.
Not just this; there is one more important reason to write clearly. Consider this formulation: Ignorance of law is no excuse. Judgments constitute law. Some judgments are utterly impossible to understand. Isn’t this Kafkaesque? But it’s true; don’t believe it? Sample this:
“This batch of writ petitions preferred under Article 32 of the Constitution of India exposits cavil in its quintessential conceptuality and percipient discord between venerated and exalted right of freedom of speech and expression of an individual, exploring manifold and multilayered, limitless, unbounded and unfettered spectrums, and the controls, restrictions and constrictions, under the assumed power of “reasonableness” ingrained in the statutory provisions relating to criminal law to reviver and uphold one’s reputation.” 
Can you imagine the Catch-22 that it spells for the litigant. The litigant is bound by a document that is simply impossible to understand. It pains me to note that the above is an extract from a judgment dealing with the very simple issue of: constitutionality of provisions in the IPC criminalizing defamation.
Now juxtapose this with how a US Trial court Judge Jed.S.Rakoff writes in Garcia v. Bloomberg, deciding on the rather vexed issue of: right of protest versus the imperatives of public order. He opens beautifully and, at the very outset, highlights the two competing ideas and values at play:
“What a huge debt this nation owes to its “troublemakers.” From Thomas Paine to Martin Luther King, Jr., they have forced us to focus on problems we would prefer to downplay or ignore. Yet it is often only with hindsight that we can distinguish those troublemakers who brought us to our senses from those who were simply … troublemakers. Prudence, and respect for the constitutional rights to free speech and free association, therefore dictate that the legal system cut all non-violent protesters a fair amount of slack. These observations are prompted by the instant lawsuit, in which a putative class of some 700 or so “Occupy Wall Street” protesters contend they were unlawfully arrested while crossing the Brooklyn Bridge on October 1, 2011.”
What a powerful introduction! This tells you exactly what you want to know about the judgement: The parties involved? Who did what to whom? What are the competing rights and interests that the court is called upon to balance in this case, so on and so forth. It further demonstrates that very difficult cases can also be decided simply (without being simplistic and while retaining academic rigor, accuracy and nuance) and presented in a format and style understandable to the reader.
Writing like Judge Rakoff isn’t easy but it isn’t impossible either. It needs work and the work, I feel, has to begin much before the actual writing of the judgment. Preparations to be made before writing the judgement are the stepping-stones to writing a good judgement:
- The basic step is reading the file comprehensively and mastering it;
- Ask informed and focused questions; this will rule out the need for seeking clarifications later.
- Make notes/charts/maps; for instance, of the crime scene, or in a family dispute – a flow chart of the family tree/pedigree. Don’t hesitate to use them in the judgment later. Sometimes, a picture says a thousand words.
- If possible, get the basic factual outline typed or prepare a draft judgment even before you begin to hear arguments; this would make your job much easier while writing the judgment and you’d know what exactly is missing. It also helps guiding the final arguments more efficiently and keeping them focused; focused at finding out that missing piece of the jigsaw puzzle. Please remember that, while we do this, we must not make a final determination and remain open to persuasion by counsel, one way or the other.
- This may sound too basic and a bit too idealistic but try and go in for an expeditious delivery of the judgment, soon after you’ve heard arguments; when you still have the memory of the case fresh in your head, instead of reserving it for later. The problem with reserving too many judgments is that it leads to, what judges in their chambers call the – ‘Conscience pile’; another word for the ever-mounting number of judgments you reserve to be written later which is not only a burden in terms of work but also on one’s conscience.
Having made the pre-judgment preparations, let’s start with a very high level view of the “Anatomy” of a good Judgment.
A good judgment should have:
- Clear articulation of the issues that arise for consideration/points of determination.
- Evidence led to prove each factual issue and appreciation of evidence on each issue.
- Applicable law and the application of law to the facts of the case.
- Reasoning and findings.
This is the basic structure of a judgment. Now let us unpack each of these components a little more:
An index is the roadmap for the judgment. Indexing makes wading through even the lengthiest judgments easy – by dividing them under different headings. The index of the Supreme Court judgment in the Ram Mandir- Babri Masjid case (shown below) is one such example; the case involved multiple issues and multiple suits and it runs through a thousand pages, but the index simplifies the job of a reader. It reads:
B. An overview of the suits
C. Evidence: a bird ‘s eye view
D. The aftermath of 1856-7
D.1 Response to the wall……”
A good index makes it easier not only for the litigant but also for the appellate court and lawyers who can directly get to the impugned part of the judgment – saving much time and effort.
Who should the Judge address the judgement to:
Amid the range of consumers of a judgement, it is the parties to the judgment who have the maximum amount of skin in the game. The students, academicians, lawyers and even the general public may despise or even mock a cryptic judgement, however, they do not stand to be impacted (at least immediately) by the creative liberties that a judge takes. The parties in the matter, on the other hand, are stuck with the judgement for the time that the same is appealed against; they have their fate determined in terms they can’t fathom. We have all heard of the anecdote of a judgment being so poorly written that both the parties filed an appeal thinking it is against them. Let’s not be that judge.
A stellar instance of speaking-to-the-audience judgement writing is Justice Peter Jackson’s Order in Lancashire County Council vs M and Others who, while deciding a child custody case, established a dialogue directly with the mother and the children. This is what he said:
“This judgment is as short as possible so that the mother and the older children can follow
The case is about a white British family. here are four children – H [a boy aged 12], A [a girl aged 10], N [a boy aged 3] and R [a girl aged 10 months]. Since July they have been living with foster carers. The younger children see their mother four times a week. The older children are at school and they come twice a week. The meetings have gone well. The mother and the children are very close and want to live together again. The mother now lives with her own mother, who I will call the grandmother……”
“6. Children can’t be taken away from their parents unless social services prove to a judge that it would be harmful for them to live at home. If children are taken away, judges will always try to return them if that is safe.
7. Another thing is that children are not taken away from their parents simply because the parents have lied about something. Even if they do tell lies they can still be good enough parents.
8. People can tell lies about some things and still tell the truth about other things.
9. Also, children are not taken away because parents are rude or difficult or because they have strange views, even if those views offend people. The only reason to take children away is because they need protecting from harm….”
“13) The mother left a message in the caravan for the father’s sister, who I will call the aunt. It told her how to look after the family’s pets. The message said that the family would be back on 3 August. It has a ☺ beside the date. After the family left, the police searched the caravan. They found the message and say that the ☺ is winking, meaning that the mother knew they wouldn’t be coming back. I don’t agree that the ☺ is winking. It is just a ☺. The police are wrong about that, and anyhow they didn’t find anything else when they searched the caravan.”
He not only customizes the language of the judgement to make it understandable to the mother and her children, but also counsels the children, who are naturally under considerable stress because of all that is happening to them and their family. It seems that, through his judgment, he holds the children by the hand and explains to them what’s happening and eases trauma. The Judge is so sensitive that he, through the judgment, explains to the children that merely because parents sometimes lie, doesn’t make them bad parents. In Para 13, he goes onto interpret an emoticon and what it means in the given context. The judge does not decide coldly but empathetically. He is mindful of the enormity of the stakes and his tone is almost like therapy.
In another ‘one-of-a kind’ show of sensitivity, the same judge wrote a judgement in the form of a letter addressed to the child whose custody was in question. The judgment starts with a short preface:
“1. In July, I heard a private law case concerning the future of a 14-year-old boy. I will call him Sam, though that is not his real name. He lives with his mother and stepfather and sees his father regularly. His father wanted to take him to live in an identified Scandinavian country….
2.At the end of the hearing, I gave my decision in the form of a letter to Sam, which I read to his parents and gave to his solicitor to give to him and to discuss with him when he returned from his trip. Sam received the decision with apparent equanimity.”
And then the Judge does something truly remarkable; In the midst of a traumatizing process, Justice Jackson, speaks to the 14-year-old child directly. This is what he says:
The Hon. Mr. Justice Peter Jackson
13 July 2017
“Dear Master X,
It was a pleasure to meet you on Monday and I hope your camp this week went well.
This case is about you and your future, so I am writing this letter as a way of giving my decision to you and to your parents. When a case like this comes before the court, the judge has to apply the law as found in the Children Act 1989, and particularly in Section 1. You may have looked at this already, but if you Google it, you will see that when making my decision, your welfare is my paramount consideration – more important than anything else. If you look at s.1(3), there is also a list of factors I have to consider, to make sure that everything is taken into account…..
“When I was appointed as a judge, I took the oath that every judge takes to apply the law in a way that is fair to everybody. Some people will say that this or that decision isn’t fair, but that’s usually their way of saying that they don’t like the decision. People who like decisions don’t usually say they are unfair. Here, your father loudly says that Cafcass is biased against fathers and during the hearing it became clear that he doesn’t have much confidence in me either. He is entitled to his view, but I can tell you that I found no sign of bias on Gemma’s part; on the contrary, I found her someone who had thought very carefully about you and your situation and used her professional experience of many, many family cases to reach an honest view of what would be for the best.
The decisions that I have to take are these: (1) should you go and live in XXX? (2) should you become a citizen there? (3) if all your parents are living in XXX, should you spend more time with your dad? (4) if your dad goes to XXX, and you stay here, how often should you see him?”
In sensitive cases, this is definitely a model worthy of emulation.
Moving on to the other parts of a good judgment, since “Well begun is half done”, a few words now on getting the startright:
Getting the Introduction right:
- The start of the judgment is “prime real-estate”. Start with a simple opening paragraph that serves as the very distillate of the case.
- Since the introduction of the case is its very essence, it may be a good idea to write it at the very end and only once you’ve totally read and internalized the case and written the other parts.
- Refrain from adding details that would have no bearing on the case, for example the incident took place at 0.00 hours on 1 January, 2019, if otherwise, timing/chronology is uncontested and not important for the outcome of the case. Same for sections and provisos.
- Stick to the golden rule: “if you can’t say it – don’t write it”
“It was a wedding banquet and the guests were enjoying themselves in the traditional custom of nuptial celebrations. There was dining and dancing and then dancing and dining. Fork work interspersed with footwork. The banquetters would enjoy a spell of eating and then amble out to the dance floor to dance. When the music suspended, the dancers returned to their tables and became diners again. The mythical playwright who prepares the script for the strange and sometimes quixotic episodes which eventually end up in court, mixed his stage properties and characters in this presentation because he placed in the center of the dance floor a quantity of freshly cooked asparagus and ladled over it a generous quantity of sauce. In this setting it was inevitable that something untoward would happen, and it did…..”
The judge starts with an interesting narration of the incident instead of a conventional opening such as “This is a case filed under so and so sections asking for so and so reliefs by the plaintiff…..”
When the judgment straight-away gets into what the case is about, the reader is hooked. Even a reader with no knowledge of law would understand what the case is about.
Contrast the above with:
“This is an application for judicial review of a District court decision delivered by XXX J on 31 November 2011 holding that the respondent’s proposed action pursuant to s.181 of the Local Government Act 2002 was ultra vires, and granting the appellant declaratory relief.”
An introduction like this says absolutely nothing about subject matter of the case; instead, it raises a lot of questions in the mind of the reader: What the hell is Section 181 of the Local Government Act, 2002?; Who did what to whom?; What is ultra vires?; so on and so forth. It doesn’t answer or communicate anything of consequence.
Thankfully, in the case under discussion, this is how the judge actually wrote the introduction:
“Can the Hutt City Council (the Council) lawfully suspend a sewage pipe above land owned by Mr. and Mrs. Cassells?”
In just one line, this introduction puts the case in its right context. Even someone who has absolutely no knowledge of law can understand that this case is about a sewage pipe, that the Judge is required to decide whether the Council can build one above the land owned by the Cassells.
Similarly, a conventional opening such as:
“Vide the present judgment, the appeal filed by the appellant is being decided. The appellant is aggrieved by the final judgment dated XXX vide which her suit for recovery of damages for wrongful termination was dismissed with costs……”
This doesn’t make for great reading at all.
Compare this with Edward Carnes J. did in. Hamilton vs Southland Christian School:
“A woman of a childbearing age was hired as a teacher at a small Christian school. Then she got pregnant, married and fired. In that order. Then she filed a lawsuit. She lost on summary judgment. This is her appeal”
It is clear that in fewer than 40 words, the Judge does a lot, she introduces the parties, recaps the key facts, the history of the litigation; what further stands out is the use of the phrase “in that order” which is absolutely refreshing and helps a reader understand the case so much better and in the right chronology.
I’ve dabbled with something similar, though with much less success and grace. In Anil Kumar v. Vimal Kumar and Surender Kumar, the issue that I was deciding was of a loan given by one friend to the other; as is often the case with friendly loans – the loan was not re-paid and the friendship ended but the loan remained. I tried opening with:
“There are two sure ways to lose a friend, one is to borrow, the other is to lend”The complainant would have the court believe that this is one such case, where he was made to part with considerable amounts by his two office colleagues Mr.X and Mr.Y with whom he came to enjoy friendly relations as they are all Government Servants, employed in the Department of XXXX, Delhi”
The endeavor was to write an introduction that gives one a brief idea of what the case is about – the flavor of the case and the primary issue that lies at the heart of the case, without burdening the reader with too many details. The reader gets the direction in which the case is headed and would want to read further to know what happens. Once, you have the spring board of a good start, the next step is dive deep right into the facts. Now, a few thoughts on getting the facts right:
Getting the facts right:
Remember “Show, don’t tell”
Every case is about human lives. Facts tell you – who is this case about? What really happened? What is the conflict about? All these things are important before one gets to the resolution of that conflict. The importance of stating the facts correctly and concisely cannot be emphasized enough.
A great way of stating facts is to stick to the most relevant facts, glean the same from the records; separate the chaff from the grain – as we lawyers love to call it. While stating facts, one must state the undisputed facts first, and then tread the more troubled waters to make a finding on the disputed ones. While clarity is paramount, in fact-intensive matters, the narration of facts must keep the reader of the judgement hooked and, instead of meticulously listing the events and happenings that make up the entirety of facts, the judgement may be shown to the readers by evoking visual imagery. And one needs to talk about only material facts. The over-arching idea is to keep the narration facts complete, concise, and interesting. Take this for instance:
“It happened on April 19, 1964. It was bluebell time in Kent. Mr. and Mrs. Hinz had been married some 10 years, and they had four children, all aged nine and under. The youngest was one. MrsHinz was a remarkable woman. In addition to her own four, she was foster-mother to four other children. To add to it, she was two months pregnant with her fifth child. on this day they drove out in a Bedford Dormobile van from Tonbridge to Canvey Island. They took all eight children with them.
As they were coming back they turned into a lay-by at Thumham to have a picnic tea. The husband, Mr Hinz, was at the back of the Dormobile making the tea. Mrs Hinz had taken Stephanie, her third child, aged three, across the road to pick bluebells on the opposite side. There came along a Jaguar car driven by Mr Berry, out of control. A tyre had burst. The Jaguar rushed into this lay-by and crashed into Mr Hinz and the children. Mr Hinz was frightfully injured and died a little later. Nearly all the children were hurt. Blood was streaming from their heads.
Mrs Hinz, hearing the crash, turning round and saw this disaster. She ran across the road and did all she could. Her husband was beyond recall. But the children recovered.”
“An action has been brought on her behalf and on behalf of the children for damages against Mr Berry, the defendant. The injuries to the children have been settled by various sums being paid. The pecuniary loss to Mrs Hinz by reason of the loss of her husband has been found by the judge to be some £115,000; but there remains the question of the damages payable to her for nervous shock – the shock which, she suffered by seeing her husband lying in the road dying, and the children strewn about.”
In barely three paragraphs, Lord Denning tells the readers about the parties, the incident, and the issue that arises for determination. All this – while painting a visual image of the scene in the reader’s mind. Lord Denning not only makes reading the facts easy for the lay person but once read, the facts remain etched in the memory of the reader for quite some time.
For a slightly more modern example, sample what Judge Scalia writes in Scott v. Harris:
“The videotape tells quite a different story. There we see respondent’s vehicle racing down narrow, two-lane roads in the dead of night at speeds that are shockingly fast. We see it swerve around more than a dozen other cars, cross the double-yellow line, and force cars traveling in both directions to their respective shoulders to avoid being hit. We see it run multiple red lights and travel for considerable periods of time in the occasional center left-turn-only lane, chased by numerous police cars forced to engage in the same hazardous manoeuvres just to keep up. Far from being the cautious and controlled driver the lower court depicts, what we see on the video more closely resembles a Hollywood style car chase of the most frightening sort, placing police officers and innocent bystanders alike at great risk of serious injury.”
The narration is of a hot pursuit that unfortunately ended in the plaintiff sustaining grievous injuries from the police car ramming into his vehicle. Scalia was ruling in a case brought against the police, alleging use of excessive force against the victim in an attempt to pull him over. Justice Scalia almost effortlessly transports us to the scene of the incident; he’s graphic and concise – all at once.
While any attempt to emulate the flair of these two masters of the skill could make one end up embarrassing themselves, certain do’s and don’ts can always come handy for modest beginners like ourselves:
- Facts are key. A trial court is essentially a court of fact; therefore, an understanding of facts is of paramount importance. At the High Court, all that a lawyer needs to do in order to get the leave to appeal is to demonstrate factual aspects not dealt-with in order get the leave granted in his/her favour.
- Good practice is to read the entire file and write the facts in one’s own words instead of reproducing the pleadings. This helps internalization and mastery over the facts. This also ensures that the judgment doesn’t look disjointed- as if written by different people in parts.
- Facts should be stated as simply as possible. The shortest distance between two points is a straight line, so there is no point beating around the bush.
- You may consider the following rules of stating facts, which the author found immensely helpful:
- Rule of CRAM (Chronological, Relevant, Admissible and Material): State only relevant, admissible and material facts, and do so chronologically.
- The rule of WDWTW (Who Did What to Whom): Not a particularly elegant formulation but one of great practical utility. The Factual narration should always answer the above.
- A good idea is to set the undisputed facts out first. It is not important to spell out why something is undisputed or where it was admitted, unless of course, the quality and nature of the admission itself is suspect and under challenge.
- It is a great idea to use the parties’ names, instead of the drab and boring – ‘plaintiff’, ‘respondent’ or ‘appellant’. This makes the judgement simpler to understand and also makes the characters of the judgment a lot more relatable. Further, it retains the humanity that the parties deserve in a judgment.
- A good exercise while writing is imagining yourself telling the facts to an intelligent, non-legal friend or your partner. As said earlier, don’t write what you won’t say out aloud, in ordinary conversation.
“A problem well stated is a problem half solved”
Issues are simply what one party asserts and the other denies. Some tips for framing of issues are summarised hereunder:
- A judgment is written to resolve a concrete issue, factual or legal, and not as an hypothetical academic exercise.
- Issues act as guiding lamp posts. Once, you have stated the issue, it would be easy to decide the case in terms of what happened and where does the liability lie.
- Rules relating to burden of proof are your friends and should be carefully used to decide who is under the obligation to prove contentious facts.
- In civil matters, the judgment should not travel beyond the pleadings or the issues. Recording findings on issues or matters which are unnecessary for disposal of the matter should be resisted. An issue is what the parties are at variance on.
- Closer to home, avoid framing generic issues such as “Whether P is entitled to grant of perpetual injunction?”
- For instance, in an application under Order XII Rule 6 of the Code of Civil Procedure, 1908 (“CPC”) Judgement on Admissions, the issue can be framed as: “Whether the defendant has admitted the claim of the plaintiff and if yes, whether the admission is complete, clear, unambiguous, unconditional and therefore, sufficient to pass a decree under Order XII Rule 6 of CPC?”.
With the treatment of issues covered, we are half-way already. We could safely say that with the introduction, facts and issue sorted, we have laid the roadmap for what would make Lord Denning very proud. However, we are yet to learn a thing or two about the most important part of a judgment: the findings; the reasons that bridge the gap between the judge’s mind and the reader’s. In Part II, we tackle the very heart of a judgment: the reasoning/findings part; we also talk about – certain words and phrases which are best avoided as they make judgments clumsy and boring. Finally, we wind up with a few thoughts on writing a killer conclusion.
First published on Bar and Bench in a three part series. You can find the remaining two parts here:
 Broadly based on a talk delivered at the Delhi Judicial Academy & J&K Judicial Academies. The views of the Author are personal.
 Lord Hewart CJ, R v Sussex Justices, ex parte McCarthy ( 1 KB 256,  All ER Rep 233)
 Subramaniam Swamy vs Union of India, (2016) 7 SCC 221
 Garcia v. Bloomberg, 865 F. Supp. 2d 478, (S.D.N.Y. 2012). 11 Civ. 6957 (JSR).
 Dessau, Linda and Tom Wodak, ‘Seven Steps to Clearer Judgment Writing’, Ruth Sheard (ed), A Matter of Judgment: Judicial Decision-Making and Judgment Writing, Education Monograph, (2003), Accessed on 18th January, 2019.
 M.L.J. Abercrombie, The Anatomy of Judgement: Investigation into the Processes of Perception and Reasoning
 M Siddiq vs Mahant Suresh Das & Ors., 2019 SCC OnLine SC 1440.
 Lancashire County Council vs. M and Others  EWFC 9
 Re (Rev 1)  EWFC 48
Dessau, Linda and Tom Wodak (supra).
 Schwartz v. Warwick-Phila. Corp., 424 Pa. 185 (1967)
Hutt City Council v. The Lower Hutt District Court, (2013) NZHC 706
 Wade Campbell Pearson, Clarity in the Court of Appeal: Measuring the readability of judgments, 2013. <https://www.otago.ac.nz/law/research/journals/otago065280.pdf>
 680 F.3d 1316, 114 FEP 1633 (11th Cir. 2012).
 Anil Kumar v. Vimal Kumar and Surender Kumar, Date of Judgment : 30.9.2015
 Patrick Rothfuss, ‘The name of the Wind’.
 Anton Chekov
 Hinz v. Berry (1971) 2 QB 40 at 42.
 Scott v. Harris, 550 U.S. 372 (2007)
 Pacific Judicial Development Programme, Judicial Decision-making Toolkit, 2015 < https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=11&ved=2ahUKEwiprcyS_pPnAhXDfH0KHUOlCvMQFjAKegQIAhAB&url=https%3A%2F%2Fwww.fedcourt.gov.au%2Fpjsi%2Fresources%2Ftoolkits%2FDecision-making-toolkit.docx&usg=AOvVaw05wcEb9FOAgpc3IIArrdaw >
 Dessau, Linda and Tom Wodak (supra)
 Charles Keterring
 Justice R.V. Raveendran, Rendering Of Judgement, 29.06.2012 < https://www.lawweb.in/2012/06/rendering-of-judgement-by-justice-rv.html >
First published on Bar and Bench in a three part series. You can find the remaining two parts here: